December 28, 2017

A trust is established in a U.S. jurisdiction such as South Dakota and a South Dakota trustee is appointed.  How could this trust be considered a non-U.S. trust?  The short answer is the U.S. Internal Revenue Service (IRS) allows trusts to be created with a U.S. situs...

December 26, 2017

As of January 1, 2017, U.S. Limited Liability Companies (“LLCs”) that are wholly owned, directly or indirectly, by one foreign person, are required to file an annual return on IRS Form 5472.  Foreign Grantor Trusts (FGT) are specifically included in the new regulation....

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